The debate surrounding the 2020 No Surprises Act (NSA)—a landmark piece of federal legislation designed to protect patients from the financial ruin of unexpected medical bills—has reached a fever pitch. On Thursday, HaloMD, a prominent billing intermediary that represents healthcare providers in payment disputes, released a provocative analysis claiming the law has successfully slashed out-of-network emergency medical spending by as much as $4 billion annually.
However, the report has been met with immediate skepticism from independent researchers, health policy experts, and economists. Critics argue that the study is a calculated lobbying effort by a firm that stands to lose significant revenue if the law’s dispute resolution process is curtailed. As lawmakers and regulators weigh potential reforms, the clash between HaloMD’s optimistic data and the stark reality described by academic institutions highlights a fundamental rift in how the U.S. healthcare system accounts for its own costs.
The Core Conflict: A Question of Savings or Costs?
The central question is whether the NSA has achieved its legislative intent: lowering healthcare costs by forcing providers and insurers to negotiate in-network contracts.
According to HaloMD, the answer is a resounding "yes." The company reports that out-of-network emergency spending has dropped by 13% to 52% since the law took effect in January 2022. HaloMD asserts that these savings, totaling between $1 billion and $4 billion, arise because the vast majority of claims—roughly 90%—are settled between insurers and providers without ever triggering the formal, and often costly, Independent Dispute Resolution (IDR) process.
"The data tells a clear story: when the entire out-of-network payment system is considered, arbitration is a small fraction of the whole," said Alla LaRoque, CEO of HaloMD. "Patients are spending less on emergency medical care today because of the No Surprises Act."
Yet, independent think tanks paint a far bleaker picture. Researchers from Georgetown University and the Brookings Institution have consistently found that the IDR process—the mechanism for resolving disputed claims—has effectively incentivized providers to remain out-of-network. By gaming the system, some providers have secured payouts far exceeding standard in-network rates, leading to an estimated $22 billion in additional, unnecessary healthcare costs over the first four years of the law’s implementation.
A Brief Chronology of the No Surprises Act
- December 2020: Congress passes the No Surprises Act as part of a year-end omnibus spending package, aiming to end "surprise billing" for patients in emergency situations and those receiving care at in-network facilities from out-of-network providers.
- January 2022: The law officially goes into effect, establishing the Independent Dispute Resolution (IDR) process as the final arbiter for billing disagreements.
- 2022–2023: A surge in IDR filings occurs. Providers, aided by specialized intermediaries like HaloMD, leverage the process to secure high payouts.
- 2024: Georgetown University releases a comprehensive report suggesting the IDR process has generated $22 billion in excess spending, sparking a national debate on reform.
- Spring 2025: The Trump administration finalizes new rules aimed at streamlining the IDR process. Insurers, however, argue the changes are insufficient to curb provider excesses.
- Late 2025/Present: HaloMD releases its own internal analysis, attempting to shift the narrative away from the "$22 billion cost" statistic by highlighting claims resolved outside of arbitration.
Supporting Data: Two Different Realities
The discrepancy between the two sides stems largely from what data points are being prioritized.
The HaloMD Perspective
HaloMD’s analysis focuses on the "macro" environment of emergency medicine. By arguing that the 90% of claims that settle privately are the real indicator of the law’s success, the firm suggests that the high costs associated with the remaining 10% (the IDR cases) are an outlier. Their model relies on the assumption that the Qualified Payment Amount (QPA)—a government-mandated benchmark for in-network rates—is a fair proxy for market-rate settlements.
The Independent View
Academic researchers argue that the HaloMD model is fundamentally flawed. Jack Hoadley, a professor at Georgetown’s Center on Health Insurance Reforms, notes that HaloMD’s narrow focus on emergency medicine hides the true inflationary impact of the law.
"Emergency medicine is actually lower in terms of the typical award levels compared to some of the other specialties out there," Hoadley explains. "If you look at surgery or plastic surgery, the payouts are significantly higher—sometimes reaching 3,000% of the benchmark."
Furthermore, Loren Adler of the Brookings Institution points out that HaloMD’s study lacks a rigorous research design. "It doesn’t look like there’s actual data at play here," Adler noted. "They’re just making assumptions without any clear basis. There’s no research design to draw any causal effect."
Official Responses and Industry Dynamics
The industry response to the report has been chilly. Insurers and policy experts suggest that HaloMD is not acting as a neutral observer, but as a party with a massive financial stake in the status quo.
HaloMD was founded in 2022 specifically to help providers navigate and win surprise billing contests. The firm earns a commission on the net payment awards it secures for its clients. With a success rate of over 90% in IDR cases and a track record of securing payouts nine times higher than in-network rates, the company has seen explosive growth.
This success has brought scrutiny. An investigation by Stat News earlier this year highlighted the lavish lifestyle of HaloMD’s founders, Alla and Scott LaRoque, drawing sharp criticism from insurance companies that have sued the firm for allegedly "gaming" the arbitration system. HaloMD has consistently denied any wrongdoing, maintaining that they are simply using the law as it was written to ensure their clients are paid fairly.
Implications: The Future of Healthcare Reform
The implications of this debate are profound for the U.S. healthcare system. If the federal government accepts the narrative that the NSA is working, the push for regulatory reform may stall. If, however, the "Georgetown consensus" holds—that the law is inadvertently ballooning healthcare costs—Congress may be forced to intervene.
1. Regulatory Hurdles
The recent rule changes from the Trump administration represent a compromise that has satisfied almost no one. While it aims to centralize the dispute process, it fails to address the underlying financial incentives that make it more profitable for a provider to be out-of-network than in-network.
2. The Lure of Litigation
As long as the IDR process offers the potential for payouts at 1,000% or more of the QPA, firms like HaloMD will continue to flood the system with claims. This creates a "clog" in the administrative pipeline, forcing even more reliance on third-party intermediaries.
3. The Patient Experience
While the No Surprises Act has undeniably succeeded in its primary goal of protecting patients from receiving "balance bills" at the kitchen table, the long-term impact on insurance premiums remains a major concern. If the cost of "surprise" care continues to rise through arbitration, those costs will inevitably be passed down to consumers through higher premiums and reduced coverage options.
Conclusion: A Calculated Narrative
The release of the HaloMD report is clearly intended to serve as a firewall against impending reform. By framing the NSA as a successful cost-saving measure, the company hopes to preserve a business model that is currently under siege by both regulators and the insurance industry.
For policymakers, the challenge remains to look past the "arithmetic exercises" provided by industry stakeholders and focus on the systemic data. Until the financial incentives for remaining out-of-network are neutralized, the "No Surprises" era of American healthcare will likely continue to produce plenty of surprises—most of them expensive.
